I think it really depends on the way this is implemented. I see nothing wrong with an action plan, per se. If the director is participating in a supportive manner to assist the employee in coming up with an action plan, assisting with the formatting, suggesting references, etc., then it could be a potentially constructive intervention. If, however, the director is not providing any guidance, support, or assistance, and is letting the employee flail about in stormy seas, then no, I'd have to say it's not something I'd advocate for. And, I do not think the employee should be required to do this on unpaid time. It should be on paid time and in a supportive environment. Otherwise, it is punitive and may be actionable by the labor union if there is one, or if not, then by the State Labor Board.